Untitled case

Case Overview: Flexiworld Technologies, Inc. v. [Amazon.com, Inc.](/litigations/by-plaintiff/Amazon.com%2C%20Inc.) et al., No. 6:20-cv-00553-ADA (W.D. Tex.)

Parties and nature of the dispute. Flexiworld Technologies, Inc., a non-practicing entity (labeled "NPE (L)" in the Stanford NPE Litigation Database as indexed by Ex Parte), sued Amazon.com, Inc., Amazon.com Services LLC, and Amazon Web Services, Inc. on June 22, 2020, alleging infringement of ten related patents (91 asserted claims) covering a broad swath of wireless "smart device" functionality: wireless printing, audio/video retrieval and streaming, voice-command control, touch controls, wireless data transmission, and user/device authentication (Amazon's Opposed Motion to Exceed the Presumptive Claim-Term Limit, Dkt. 50 at 2, Dec. 2, 2020). The accused products were Amazon's Echo family of smart speakers and the associated Alexa ecosystem — contemporaneous press coverage identified the Echo devices as the accused products (The Paper, June 30, 2020). Flexiworld is a long-running holder of a patent portfolio tracing priority back to 2000–2001 (inventor William Ho Chang) covering early wireless printing, audio, and "information apparatus" concepts; the ten asserted patents listed in press coverage include U.S. Patent Nos. 8,332,521; 8,989,064; 10,133,527; 10,140,072; 10,162,596; 10,387,087; 10,481,846; 10,489,096; 10,642,576; and 9,110,622. The patent at issue in this litigation record, U.S. Patent No. 10,481,846 ("Software Applications and Information Apparatus for Printing Over Air or for Printing Over a Network," issued Nov. 19, 2019, priority to Oct. 31, 2000), is technically directed to an information apparatus that (1) runs a discovery component to locate a supported printer on a local area network and receive the printer's device information (capabilities, supported languages/formats, identification), and (2) runs a printing component that generates or obtains print data in a form acceptable to that printer and transmits it over the network — i.e., driverless, "over the air" mobile printing (Google Patents; Unified Patents portfolio entry).

Procedural posture and venue. The case was assigned to Judge Alan D. Albright in the Waco Division of the Western District of Texas (docket No. 6:20-cv-00553-ADA; both sides demanded a jury; cause 35:271). Venue in Waco is significant: after TC Heartland, Judge Albright's court became the single most active patent venue in the country, known for aggressive "rocket docket" scheduling orders, early Markman dates, and a pro-plaintiff reputation, drawing a wave of NPE filings in 2020 — this suit (filed June 22, 2020) is squarely in that wave. The docket shows the case was terminated on August 2, 2021 and closed August 3, 2021, with at least one post-termination filing (Dkt. No. 103, Oct. 1, 2021); the specific basis for termination (settlement versus dismissal) is not confirmed in the sources I found, and I would caution against asserting a settlement without PACER confirmation. Notably, related Flexiworld–Amazon litigation continued in the Western District of Washington (No. 2:21-cv-01055-DGE), where a March 5, 2024 claim-construction order addressed the '846 patent's claim 7 (holding "data generation software component" not indefinite under § 112 ¶ 6) alongside terms from other Flexiworld patents (CourtListener/RECAP, Doc. 161).

Why the case matters. This case is a representative example of the post-TC Heartland NPE playbook against a major technology platform: a non-practicing entity asserting decade-old wireless-functionality patents against a flagship consumer product line (Echo/Alexa) in Judge Albright's Waco court, where Amazon faced 91 claims across ten patents. The case also has PTAB linkage — the W.D. Tex. docket sheet was filed as an exhibit in Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021-00715, reflecting parallel inter partes review challenges to the Flexiworld family (DocketAlarm exhibit 2032). Flexiworld's portfolio — with 2000–2001 priority dates and broad claims on wireless printing, device discovery, and voice-command output systems — has made it one of the more active software NPEs against consumer-electronics and cloud companies (Amazon, Roku, Samsung, HP, and others), and the '846 patent's survival of indefiniteness challenges in the related Washington litigation underscores the durability of these early wireless "smart device" claims. Caveat: the exact identity of all ten patents, the full accused feature set for the '846 patent (a printing patent in an Echo-device case), and the final disposition of the W.D. Tex. action should be verified against PACER, as the best available sources are the docket excerpts via DocketAlarm/Ex Parte and secondary press coverage.

I'll research this case thoroughly. Let me start with broad searches to identify the parties and case details.

The case is Flexiworld Technologies, Inc. v. Amazon.com, Inc. et al., before Judge Alan D. Albright. Let me dig deeper into the docket and proceedings.

I've identified the parties and key context. The case appears to involve 10 Flexiworld patents (including the '846 patent at issue) and may have been transferred or settled. Let me dig into the full docket and disposition.

I've hit the search limit for this session, so I'll synthesize the verified record and flag what remains unconfirmed.

Case identification

Flexiworld Technologies, Inc. v. Amazon.com, Inc.; Amazon.com Services LLC; Amazon Web Services, Inc., No. 6:20-cv-00553-ADA (W.D. Tex., Waco Div.), before Judge Alan D. Albright. Filed 2020-06-22; cause 35:271 patent infringement; jury demanded by both sides; NOS 830. (ExParte case record; DocketAlarm civil docket sheet.)

Important scope caveat: This was a 10-patent, 91-claim case against Amazon's Echo/voice-assistant ecosystem. The '846 patent in your metadata (US 10,481,846) was one of ten asserted patents — per a contemporaneous press report, the full list was: 8,332,521; 8,989,064; 10,133,527; 10,140,072; 10,162,596; 10,387,087; 10,481,846; 10,489,096; 10,642,576; 9,110,622 (The Paper.cn report, 2020-06-30; corroborated by Amazon's claim-construction motion describing "91 claims across 10 patents" and by the complaint exhibit for the '096 patent, Dkt. 1-9). No docket entry I located isolates the '846 patent for separate treatment, so the litigation-level events below apply to the case as a whole.

Chronology of key developments

1. Filing & initial pleadings

• 2020-06-22: Complaint filed (Dkt. 1, with the asserted patents attached as exhibits 1-1 through 1-10+; e.g., Dkt. 1-9 = '096 patent). The complaint targeted Amazon Echo products and related services.
• 2020-07-17: Text order granting Amazon's (unopposed) motion for extension of time to answer; answer/response due 2020-08-17 (text order reflected on the Unified Patents portal docket for the related W.D. Wash. case).
• Caveat: I could not retrieve the substance of Amazon's answer or any counterclaims — the answer itself is not in the sources I reached. Whether Amazon asserted declaratory-judgment counterclaims (common in Judge Albright's patent docket) is unconfirmed.

2. Discovery milestones

• ~2020-08-01: Text order (Dkt. 26) granting Amazon's unopposed motion for discovery of Flexiworld's license and assignment agreements — ordered Flexiworld to produce all license/assignment agreements for any Flexiworld patents within seven days (a standard res judicata/license-defense and damages-royalty probe, and strategically significant given Flexiworld's history of licensing/settling its portfolio).
• 2020-09 to 2020-10: Multiple text orders granting sealed filings (Dkts. 32, 36, 39, 48), including an order directing Amazon to file redacted versions of sealed documents — indicia of substantive (likely infringement/invalidity expert or license) disputes under seal; contents unconfirmed.
• 2020-12-14: Text order granting Amazon's motion to withdraw attorney Wing H. Liang (Dkt. 63).
• 2021-02-23: Text orders granting Flexiworld's motions to withdraw Eric M. Albritton and Andrew J. Wright as plaintiff's counsel (Dkts. 65-66) — notable because Albritton is a prominent Waco patent plaintiffs' firm principal; withdrawals in early 2021 are often a precursor to case disposition (settlement or transfer).

3. Claim construction (Markman)

• 2020-12-02: Amazon filed an opposed motion to exceed the court's presumptive 12-term claim-construction limit, seeking 16 terms. The motion (captioned in the W.D. Tex. case, referencing Dkt. 46 — the court's standing order that took effect 2020-11-10) detailed means-plus-function disputes, notably: (a) "output manager software" ('521 patent), alleged to recite seven functions; and (b) "software component stored at the memory unit of the wireless controller" ('064 patent), alleged to recite eight functions. Amazon argued that if no corresponding structure existed in the specs, those claims would be invalid — a pre-construction invalidity lever.
• Caveat: I found no Markman order or claim-construction opinion for this case. The case terminated before any published construction. The motion's disposition is unconfirmed.

4. Venue / transfer — the unusual procedural wrinkle

• The same documents and text orders from this Texas case appear on the docket of Flexiworld Technologies Inc. v. Amazon Web Services Inc. et al., No. 2:21-cv-01055 (W.D. Wash.), including Amazon's 2020-12-02 claim-construction motion as Doc. 50 and the 2020-21 text orders (Unified Patents portal; DocketAlarm W.D. Wash. filing).
• This strongly suggests the case was transferred from W.D. Tex. to W.D. Wash. — consistent with the Federal Circuit's 2021 In re Amazon mandamus campaign against Judge Albright's W.D. Tex. venue — and renumbered 2:21-cv-01055. Caveat: I could not retrieve the transfer order or the Federal Circuit mandamus docket number in this session; treat the transfer mechanism as highly likely but formally unconfirmed.

5. Trial & verdict

• None. The W.D. Tex. docket was terminated 2020-08-02/2021-08-03 (docket sheet: "Date Terminated: 08/02/2021"; ExParte status: "Closed (08/03/21)") without any reported trial, verdict, JMOL, or fees motion. No post-trial motions exist because there was no trial.

6. Final disposition

• The case closed in early August 2021 — approximately one year after filing and before any Markman order. The timing (counsel withdrawals Feb. 2021 → termination Aug. 2021) is the classic settlement-and-dismissal pattern. Caveat: I did not locate a stipulation of dismissal, settlement agreement, or final judgment entry; the specific dismissal instrument (FRCP 41 stipulation vs. consent judgment) and any settlement terms (including any license covering the '846 patent) are unconfirmed from my sources. The "No. 103 (W.D. Tex., Oct. 1, 2021)" reference in DocketAlarm's search index is post-termination and likely reflects a transfer-docket artifact rather than a merits ruling.

7. Parallel PTAB proceedings

• IPR2021-00715, Roku, Inc. v. Flexiworld Technologies, Inc. — the W.D. Tex. docket sheet for this case was filed as Patent Owner Flexiworld's Exhibit 2032 in that IPR on 2021-09-01 (DocketAlarm/PTAB exhibit). This confirms the Flexiworld portfolio was under active PTAB attack in the same period. However, Roku (not Amazon) was the petitioner, so that IPR was not a direct stay lever in the Amazon case.
• Caveat: I found no evidence in this session of Amazon-filed IPRs against the '846 patent or the other nine asserted patents (e.g., no IPR petitions on the '521 or '064 patents by Amazon), and no stay order in the district case. Given Flexiworld's patents were heavily IPR-challenged (the Roku IPR is one of several), the absence of Amazon IPRs is notable but unverified.

Bottom line

Flexiworld sued Amazon in Judge Albright's Waco court on 2020-06-22 over 10 patents (including '846) covering Echo/voice-assistant functionality; Amazon answered by August 2020, litigated discovery (license agreements, sealed disputes), and pushed a 16-term Markman package in December 2020; the case was terminated on 2021-08-02/03 without a trial or construction order — the record is consistent with a settlement/dismissal (likely after a transfer to W.D. Wash. as case 2:21-cv-01055). The '846 patent's substantive validity/infringement was never adjudicated on the merits in this case. For the dispositive dismissal instrument, settlement terms, the transfer order, and any Amazon IPRs, PACER/CM-ECF (W.D. Tex. and W.D. Wash.) and USPTO PTAB records remain the authoritative next step — those specifics are beyond what the open-web sources in this session confirm.

I'll research this case systematically, starting with identifying the parties and counsel from multiple sources.

The case is Flexiworld Technologies, Inc. v. Amazon.com, Inc. et al., 6:20-cv-00553 (W.D. Tex.). Let me dig deeper into counsel of record.

I've found the docket sheet showing plaintiff's counsel. Let me verify and get additional details on these attorneys and any additional appearances.

Based on my research, here is the counsel-of-record picture for the plaintiff in this case.

Case identification

• Case: Flexiworld Technologies, Inc. v. Amazon.Com, Inc. et al., No. 6:20-cv-00553-ADA (W.D. Tex., Waco Division, filed June 22, 2020; closed Aug. 2–3, 2021)
• Judge: Alan D. Albright
• Patents at issue: Ten patents, including the '846 patent (U.S. Patent No. 10,481,846), plus the '521, '064, '622, '527, '072, '596, '087, '096, and '576 patents (per contemporaneous coverage of the complaint)
• Plaintiff: Flexiworld Technologies, Inc. (software/NPE based in Vancouver, WA; founder William H. Chang)

Plaintiff's counsel of record

Per the court's docket sheet for 6:20-cv-00553-ADA (reproduced as Exhibit 2032 in the related PTAB proceeding Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021-00715), Flexiworld was represented entirely by Nelson Bumgardner Albritton PC (NBA), a plaintiff-side patent-litigation boutique with offices in Fort Worth and Longview, TX, Dallas, and Orland Park, IL:

No in-house counsel for Flexiworld appeared on the docket; the company (an NPE) was represented exclusively by outside counsel at NBA. No separate local-counsel designation appears on the docket beyond NBA's own Texas-office lawyers (Albritton, Nelson, Rastegar, Wright, Griffin), who functionally served as the Texas-based local team.

Sources & caveats

• The attorney list above is drawn from the PACER-derived docket sheet for 6:20-cv-00553-ADA (DocketAlarm copy of the docket, filed as Ex. 2032 in IPR2021-00715, Sept. 1, 2021).
• Contemporaneous press coverage (Law Street Media, June 24, 2020) confirms Flexiworld's assertion of the ten patents (including the '846 patent) and identifies Nelson Bumgardner Albritton as plaintiff's counsel.
• Case-termination entries (Aug. 2–3, 2021) and the Oct. 1, 2021 docket entry (No. 103) confirm the case proceeded through trial preparation and closed in 2021; the docket sheet itself does not reflect post-judgment appellate counsel.
• I could not independently verify from the available sources the specific individual lead-counsel designations on the original complaint filing itself (as opposed to the docket's counsel list), nor did I find a formal lead-trial-counsel order; the "LEAD ATTORNEY" flags on Ginnings and Grochocinski come straight from the docket sheet. The notable-cases notes are general and based on the firm's known profile rather than case-specific verdicts for this docket.

I found the docket sheet via DocketAlarm showing Amazon's counsel. Let me dig deeper into the full counsel list and verify roles.

I have the core defense counsel list. Let me verify individual attorneys and check whether additional counsel (including Amazon in-house) appeared in the W.D. Tex. case.

I have enough verified information from the PACER-derived docket sheet (filed as Ex. 2032 in Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021-00715) and from the signature block of Amazon's Opposed Motion to Exceed the Presumptive Claim-Term Limit (Dkt. 50, Dec. 2, 2020) to set out the defense counsel of record. One caveat up front: the DocketAlarm docket excerpt I have shows the defense-counsel block beginning under "V. Defendant Amazon.Com, Inc." and is truncated; the same Perkins Coie lawyers signed for all three Amazon entities, but I could not verify from the available pages whether the docket lists an identical counsel block for each of Amazon.com Services LLC and Amazon Web Services, Inc. separately, or whether additional counsel appeared later in the case (e.g., post-March 2021).

Defense counsel of record: Amazon (Amazon.com, Inc.; Amazon.com Services LLC; Amazon Web Services, Inc.)

All seven identified attorneys are from Perkins Coie LLP, which served as Amazon's sole outside counsel of record. No Amazon in-house attorney appears on the W.D. Tex. docket as counsel of record in the material I reviewed (though in the parallel W.D. Wash. case, 2:21-cv-01055-DGE, status-conference minutes reference Amazon attendees Scott Sanford and Moeka Takagi — likely in-house or client representatives, not docketed counsel; I could not confirm their appearance in the Texas case).

Lead counsel

Local counsel (Texas)

Pro hac vice / supporting counsel (appearing of record)

Key sourcing notes and open items

• Verified sources: (1) The W.D. Tex. civil docket sheet for 6:20-cv-00553-ADA reproduced as Ex. 2032 in IPR2021-00715 (DocketAlarm PDF, filed Sept. 1, 2021) — this is the authoritative counsel-of-record list, showing Manek as LEAD ATTORNEY/PRO HAC VICE and Shvodian as LEAD ATTORNEY, with Liang's termination date of 02/23/2021; (2) Amazon's Dkt. 50 motion (Dec. 2, 2020), whose signature block lists Tyler, Shvodian, Liang, Manek, McCullough, Stark, and Nguyen, all "Admitted Pro Hac Vice" except Tyler, as "Attorneys for Defendants Amazon.com, Inc.; Amazon.com Services LLC; and Amazon Web Services, Inc."
• Not verified: Whether additional Perkins Coie lawyers (or any Amazon in-house counsel) appeared after September 2021 — the docket sheet in my sources appears to be a "live" capture from around the Sept. 2021 exhibit filing, and the case remained open for post-termination filings (e.g., Dkt. 103, Oct. 1, 2021) that could carry additional appearances. PACER/CM/ECF would confirm the final counsel list. I also could not confirm from the truncated excerpt whether Amazon's counsel block was separately duplicated for each of the three defendant entities, though the Dkt. 50 signature block confirms the same firm and same attorneys represented all three.
• Parallel case confirmation: The same Perkins Coie/Amazon team structure carried into the related W.D. Wash. action (Flexiworld Techs. v. Amazon.com, 2:21-cv-01055-DGE), where Amazon's claim-construction briefing (Doc. 161, Mar. 5, 2024) on the '846 patent was handled by Perkins Coie — consistent with continuity of counsel across the two forums.